Privacy Policy and PDP Law Disclosure Text

## 1. Data Controller

This Privacy Policy and PDP Law (Personal Data Protection Law) Disclosure Text has been prepared regarding personal data processed through sales channels, the website, marketplace stores, social media accounts, customer communication channels, and other digital platforms operated by ELMA ART AKSESUAR SANAYİ VE TİCARET LİMİTED ŞİRKETİ.

Data Controller: ELMA ART AKSESUAR SANAYİ VE TİCARET LİMİTED ŞİRKETİ  
Address: Fatih Mah. 1197 Sk. No: 2 Gaziemir / İzmir   
E-mail: destek@velonihome.com  
Support / Marketing E-mail: pazarlama@elmaaksesuar.com  

Our company attaches importance to the protection of personal data and processes personal data in accordance with the relevant legislation, primarily the Personal Data Protection Law No. 6698.

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## 2. Processed Personal Data

Depending on the nature of the products and services offered, the following personal data may be processed by our company:

- Name and surname,
- Phone number,
- E-mail address,
- Delivery and billing address,
- Order information,
- Billing information,
- Payment and collection information,
- Shipping and delivery information,
- Customer requests, complaints, and support records,
- Return, cancellation, and exchange information,
- Website usage information,
- IP address, cookie records, and transaction security data,
- Marketing communication preferences,
- Social media or digital advertising interaction information.

Your payment information may be processed via the payment infrastructure used or through the bank. Depending on the technical structure of the payment infrastructure, our company may not store your card details directly.

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## 3. Purposes of Processing Personal Data

Your personal data may be processed for the following purposes:

- Receipt, preparation, and delivery of orders,
- Execution of product sales, billing, and collection processes,
- Management of shipping and logistics processes,
- Responding to customer support requests,
- Execution of cancellation, return, exchange, and warranty processes,
- Provision of after-sales services,
- Execution of accounting, finance, and legal record processes,
- Fulfillment of legal obligations,
- Execution of company internal operations and business processes,
- Measurement of customer satisfaction,
- Evaluation of requests and complaints,
- Ensuring the security of the website and digital channels,
- Prevention of fraud and misuse,
- Execution of campaign, promotion, marketing, and commercial electronic message processes, provided that you have given your explicit consent.

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## 4. Method of Collecting Personal Data

Your personal data may be collected electronically or physically via;

- Website,
- Marketplace stores,
- Order forms,
- Phone calls,
- E-mail correspondence,
- Social media messages,
- Shipping and delivery processes,
- Payment and billing systems,
- Cookies and digital analysis tools,
- Customer service and support channels.

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## 5. Legal Grounds for Processing Personal Data

Your personal data may be processed based on the following legal grounds within the scope of Article 5 and relevant articles of the PDP Law No. 6698:

- The processing of data being necessary for the establishment or performance of a contract,
- The data controller being able to fulfill its legal obligation,
- The processing of data being mandatory for the establishment, exercise, or protection of a right,
- The legitimate interest of the data controller, provided that it does not harm the fundamental rights and freedoms of the data subject,
- Being expressly provided for in the laws,
- Your explicit consent, where necessary.

Marketing, campaign, advertising, and commercial electronic message transmissions are conducted in accordance with your explicit consent or the conditions stipulated in the relevant legislation where necessary.

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## 6. Parties to Whom Personal Data May Be Transferred

Your personal data may be shared with the following persons and institutions, limited to the purposes stated above:

- Shipping and logistics companies,
- Payment institutions, banks, and financial service providers,
- Accounting, financial consultancy, and audit service providers,
- E-commerce infrastructure providers,
- Marketplace platforms,
- Software, server, hosting, technical support, and security service providers,
- Advertising, marketing, and analysis service providers,
- Legal consultants and authorized representatives,
- Authorized public institutions and organizations,
- Courts, enforcement offices, and other legal authorities.

Your personal data is transferred only to the extent necessary and in accordance with the relevant legislation.

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## 7. Retention Period of Personal Data

Your personal data is retained for the period required by the purposes of processing and for the legal retention periods stipulated in the relevant legislation.

Order, invoice, accounting, payment, return, and delivery records may be retained for the legal periods within the scope of obligations arising from tax, commercial, consumer, and accounting legislation.

Upon the expiration of the retention period or the disappearance of the processing purpose, your personal data will be deleted, destroyed, or anonymized.

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## 8. Cookies and Digital Tracking Technologies

Cookies may be used on our website to improve user experience, measure site performance, ensure security, develop services, and conduct marketing activities.

Data collected via cookies may include site usage information, visited pages, session information, device, and browser information.

You can delete, block, or change your cookie preferences via your browser settings. However, if some cookies are disabled, some features of the website may not function properly.

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## 9. Commercial Electronic Messages

Commercial electronic messages containing campaigns, discounts, promotions, advertisements, product information, and marketing are sent in accordance with relevant legislation and with your consent where necessary.

You may refuse to receive commercial electronic messages, change your communication preferences, or unsubscribe at any time.

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## 10. Security of Personal Data

Our company takes care to implement the necessary technical and administrative measures to prevent unlawful processing of and unauthorized access to personal data and to ensure the secure retention of data.

In this context, access authorizations, secure system usage, data minimization, record tracking, service provider audits, and other necessary security measures may be implemented.

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## 11. Rights of the Data Subject

Within the scope of the PDP Law, individuals whose personal data is processed may exercise the following rights by applying to the data controller:

- To learn whether their personal data has been processed,
- To request information if their personal data has been processed,
- To learn the purpose of processing and whether the data is used in accordance with its purpose,
- To know the third parties to whom the personal data is transferred,
- To request the correction of incomplete or incorrectly processed personal data,
- To request the deletion or destruction of personal data within the scope of the conditions stipulated in the legislation,
- To request that the correction, deletion, or destruction be notified to third parties to whom the personal data has been transferred,
- To object to an adverse outcome resulting from the analysis of processed data exclusively through automated systems,
- To request compensation for damages in the event that personal data is processed unlawfully.

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## 12. Method of Application

You may submit your requests regarding your personal data through the following communication channels:

ELMA ART AKSESUAR SANAYİ VE TİCARET LİMİTED ŞİRKETİ  
Address: Fatih Mah. 1197 Sk. No: 2 Gaziemir / İzmir    
E-mail: destek@velonihome.com  
Support / Marketing E-mail: pazarlama@elmaaksesuar.com  

Your applications will be evaluated as soon as possible and within the periods stipulated in the legislation, depending on the nature of your request. Additional information or documents may be requested in cases requiring identity verification.

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## 13. Policy Changes

Our company may make changes to this Privacy Policy and PDP Law Disclosure Text in line with legislative amendments, service processes, or operational needs.

The current text is valid as of the date it is published on the website or the relevant sales channel.

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## 14. Contact

You can contact us for all your requests regarding privacy, personal data, orders, delivery, returns, and customer support processes.

E-mail: destek@velonihome.com  
Support / Marketing E-mail: pazarlama@elmaaksesuar.com